Atkinson: LiP’s behaviour very far out of the norm
The High Court has imposed a civil restraint order (CRO) on a litigant in person (LiP) who made “numerous meritless applications” as part of a claim against his former solicitors.
Duncan Atkinson KC, sitting as a deputy High Court judge, ordered the LiP, anonymised in the ruling as ‘KKK’, to pay over £70,000 in costs on an indemnity basis and £40,000 on account for further costs.
KKK launched a claim against Elena Tsirlina, trading as Blokh Solicitors, in June 2024 for breach of contract and confidentiality.
Judge Atkinson struck it out in April 2025 and has rejected various other applications, including to recuse himself.
KKK had throughout “raised numerous meritless applications”, he said. “He has failed repeatedly to comply with any number of court orders, and has done so in a deliberate, if not belligerent, way.”
Judge Atkinson said It was “entirely clear to me” that “there is a very real need for there to be a limited civil restraint order in relation to this claimant”.
The judge quoted from two emails sent by KKK which “amply demonstrated” his attitude.
In the first, sent in April 2025 to Ms Tsirlina and her solicitors, Caytons, KKK said he was “in no hurry” as he bore “no legal costs” in pursuing the claims and “you have no realistic prospect of recovering any legal fees from me”.
The following month, KKK told Caytons he would go to the European Court of Human Rights if necessary: “If you believe that I will grow tired or give up – you are mistaken. We are only at the beginning.”
The judge said KKK had “chosen to communicate not only with the court’s Listing Office and the identified contact at the defendant’s solicitors”, but with “others working for that firm directly, the defendant herself directly, counsel instructed to represent the defendant directly, and the judge dealing with proceedings directly.
“Such direct contact is not only contrary to directions given by this court on a number of occasions during the course of these proceedings, but also is wholly unacceptable.”
Judge Aktinson said it was necessary not only to specify that KKK only communicate with the listing office and the nominated contact at Caytons, but also to include a penal sanction.
The judge was “wholly satisfied” that the test for a costs order on an indemnity basis was met and KKK’s behaviour took the case “very far out of the norm”.
KKK had “failed to comply with a series of court orders or to apply for relief from sanctions”.
He had “sought to email repeatedly and prodigiously the defendant’s counsel, the judge, a host of representatives from the defendant’s solicitors and others in a disproportionate way that has put a significant burden on both the defendant, those acting for her and, indeed, on the court”.
He had “made a series of applications, or has sought to advance matters intended as applications not in proper form, without merit and without, even when directed to do so, evidence either of their proper service or, indeed, of an evidential basis for them”.
Judge Atkinson ordered KKK to pay costs of £70,700 on the indemnity basis for two hearings related to KKK’s claim and Ms Tsirlina’s application for a strike out.
For two further hearings relating to KKK’s application set aside the judgment striking out the claim, the judge ordered KKK to make a payment on account of £40,000.
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